ML20148H235
| ML20148H235 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/22/1988 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| To: | Devine, Dixon GOVERNMENT ACCOUNTABILITY PROJECT |
| Shared Package | |
| ML20148H240 | List: |
| References | |
| FOIA-84-743, RTR-NUREG-0675, RTR-NUREG-675 NUDOCS 8801270176 | |
| Download: ML20148H235 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION Nec pota s.
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INFORMATION ACT (FOIA) REQUEST
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Itoutsitm PART l.-RECORDS RELEASED OR NOT L6CATED (See checked bones)
No egency records subst to the request have been located.
No additonal agency reco.ds sub,ect to the requwt have been located.
Agency recoffs subsect to the roovest that are identfed in ApperiJ.:
U are ausady avadable for pubhc repecton and cop % in the NRC Pubhc Document Room, 1717 H Street. N W.. Wuhmgton DC.
Agency records subsect to the roovest that are identrfed in Appendin are teing rnado avadable for pubhc mspecton and copying in the NRC Pubhc Document floom.1717 H Street. N.W.. Washmgton, DC, in a folder under the FOtA number and requester name e
The nonpropnetary verson of the proposalis) that you agreed to accept m a towphone conversation wth a member of my staN e tw being made avalable for pubhc especton and coying at the NRC Pubhc Document Room.171? H Street. N W. Washmgton. DC. m a fc4 der ureer ;his FOtA number and requester name.
Enclosed is mformaton on how you may obtae access to and the charges for copyeg.ecords placed in the NRC Public Document Room,1717 H Street N.W., Wuhmgton. OC.
Agency records e,brect to the request are enclosed Any appbcable charge for cop.es of the ecords proveed and payment procedures are noted m the comments secton.
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Records subect to the request have been re' erred to another Federal agencybes) for reww are detect response to you.
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In M of NRC s.esponse to the requ6st. no furtner action is bemg taken on appeal letter dated PART 11 A-INFORMATION WITHKELD FROM PU8UC DISCLOSURE
ertam ir forrr.o.:. vi the Novosted records is bemg wthheld from putdic desclosure pursuant to the FOIA esemptions described m and for the reasons sta.ed in Part H. sec-t:ons B. C. er4 G ny rewased wtons of the documents for which ordy part of the record a being wettheid are bemg made avadable for pubhc inspecton and copymg m the NRC PuW Document Roum.1717 H Streat. N W.. W",hington. OC. m a fo6 der under the FOI A number and requester narm.
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OAT i'A^uT 118-A; PLIC"8tE FOI A EXEMPTIONS Records subject to the request that are described in the enclosed Appendices MO_
are being withheld in theer entirety or in part under FOIA Esemptions and for the reasons set forth below pursuant to 5 U.S.C. 552(b) and 10 CFR S 5(a) of NRC Regulations.
- 1. The wthheM information is property classsted pursuant to Enocutive Order 12356 (EXF.MPTION 16
- 2. The wthheld mformation reistes solety to the internal personnel rules and procedures of NRC. (EXEMPTION 2)
- 3. The wthhe'd information is specsfcaay esempted from putAc declosure by statute indicated. IEXEMPTION 31 Secton 141145 of the At~. Enygy Act wNch prohbts the d4 closure of Restncted Osta 'or Formerfy Restncted Data 142 U.S C. 216121651.
Secton 147 of the Atomic Energy Act whech prohbts the d sclosure of UnclassAed Safeguards informenon 142 U S.C. 2167L
- 4. The wthheld informabon is a trade secret or commercal or fmancial eformaton that o being wthhead for the reasonis) ed*cated. IEXEMPTION 4)
The informton a considered to be conf 4entel bscess (proonetaryl eformaton.
The informaton e cons.dered to be propretary informaton pursuant to 10 CFR 2 790(d)(1L The ir* formation was subrNited and recewed in conf 4ence from a foregn source pursuant to 10 CFR 2 7%dA2L
- 5. The ethhe6d informaton conssts of mteragency or otrangency records tPat are not avadable through dscovery Juring litgaton. Declosure of predeceionalinformaton would tend to inhbt the open and frank enchange of ideas essental to the dehberatrve process Where records are wthheed m thew entssty, the facts are mettricath intertweed wth the predecmonal eformaton. There sino are no reasocatdv segregable factual portons tocause the reisase of the f acts would permet an moneet mouu y oto the predecrsional process of the agency. (EXEMPTION 5#
- 6. The wthhead information is esempted from pubhc esclosure because its dociosure would result m a clearfy unwarranted invas.on of personal privacy. (EXEMPTON 6}
? The wthhe6d informaton conosts of investgatory records compded for tan enforcement purposes and a being wtmead for the ressceis) ind.cated. (EXEMPTION 71 Decios.,e me ini-.,e wm.n.nfme,r-p,oceed.ng tesose a coow,e,eai me scope. di,ecison. and focus of en,memoei e o,a and mus coue a
possit#y allow them to take acton to sheedd potented wrongdoing or a volaton of NRC reqv temer ts from investgators (EXEMPTCN 71 AH s
Declosure would constrtute an unwarr ted invason of pesonal ornacy (EXEMPTION hCH The informaton cons,sts of names of indevewais and other eformaton the declosw e of wheth would ressalidentrees of conf 4 ental sources (EXEMPTION 7101) e PART H C-DENylNG OFFICIALS Pursuant to 10 CFM 9 9 and!or 915 of the U S. Nucinar Regulatory Commason regulatons, a has been determoed that the informaton wthroM a enerret from prodwetion or declosure.
and that its producten or declosure e coetrary to the publec mterest. The persons responsable for the denial are those officials identifed beeow as doryng officets and the Dweetor, Deveen of Rules and Records. OtSce of Adminstraton. for any den.ais tnt may to appeated to the Enocutrve Dwettor for Operatens Eooi DENytNG OFFICIAL TITLEtOFFICE MECORDS DENIED APPELL. ATE OFFICIA 6 U
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' C & G ru PART 11 D-APPEAL RIGHTS The denial by each denying officisi identified in Part II.C may be appealed to the Appettate Official identified in that section. Any such appeal must be in writing and must be made within 30 days of receipt of this response. Appeals rnust be addressed as appropriate to the Executive Dweetor for Operations or to the Secretary of the Commission. U.S. Nuclear Regulatory Commission. Wash;ngton, DC 20555, and should clearty state on the envelope and in the letter that it is an "Appeal from an initial FOIA Decision."
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U.S. NUCLEAR REGULATORY COMMISSION s asi FOIA RESPONSE CONTINUATION
l 1
F0!A-84-743 (9thPartial)
APPENDIX R RELEASED RECORDS 1.
Undated NonconformanceReport,DCO-83-SC-N007,Page2(1page).
2.
Undated Handwritten Notes (1 page).
3.
10/19/79 Ltr To Mr. V. Tennyson from J. Tompson, (5 pages).
4.
3/9/83 Inter-Office Comunication to Quality Control Supervisors, From A. E. Moses,
Subject:
Inspection Signatures (1 page).
5.
5/31/83 Howard P. Foley Company Receiving Inspection Report (1 page).
6.
6/10/83 PG8E Nonconfonnance Report (1 page).
7, 10/6/83 Pullman Power Products Field Warehouse Requisition ('? pages).
8.
8/15/83 Howard P. Foley Company Inspection Report (3 pages).
9.
10/20/83 Inter-Office Memo to J. Thompson /Q. A. Manager from L. R.
Wilson / Quality Director,
Subject:
Level I Signatures (1 page).
- 10. 3/5/84 Problem Statement, Allegation f(s): 166,ATSNo.(s):
RV-84A-0021(1page).
- 11. 3/11/84 Double space report: Task: Allegation or Concern No.166, ATS No.: RV-84-A-0021 (6 pages).
- 12. 3/16/84 Problem Statement, Allegation No(s): 142(5pages).
- 13. 3/23/84 LTR to Mr. John B. Martin, from J. O. Schuyler,
Subject:
Docket No. 50-?75, OL-DPR-76, Diablo Canyon Unit 1. Welding of ASTM A-325 Type 1 Bolts (5 pages).
i FOIA-84-743 (9thPartial)
APPENDIX S P0RTIONS OF RECORDS WITHHELD EXEMPTIONS 6 AND 7(C) 1.
Undated Handwritten notes (2 pages).
2.
Undated Handwritten notes (1 page).
3.
Undated Handwritten notes (4 pages).
4.
Undated Handwritten notes No. 132 (1 page).
5.
Undated Typed questions (? pages).
6.
Undated Telecon from M. M. Mendonca and M. Padovan, #196-199, RV-84A-0027 Handwritten (2 pages) 7.
The Howard P. Foley Company Inspection Report (2 pages).
8.
12/20/83 Allegation Da+.a Fom (4 pages).
l 9.
1/84 Allegation #166, ATS. NO. RV-84A-0021 (1 page).
10.
1/2/84 Ltr to Mark Padovan (29 pages).
11 1/4/84 Sumary of Special Insp. Related Information (175 pages).
12.
1/17/84 Sumary of Special In3p. Related Infomation (1 page),
i
- 13. 2/21/84 Allegation Data Fom w/ attachment dated 3/12/84 memo for file RV-84-A-0033 (2 pages).
14, 3/1/84 Allegation Data Fom RV-84-0037 w/ attachments (11 pages).
15, 3/1/84 Allegation Data Fom RY-84-0036 w/ attachments (e pages).
16.
3/1/84 Allegation Data Fom RY-84-A-0034 w/ attachment (2 pages).
- 17. 3/5/84 Problem Statement, Allegation #26 (2 pages).
18, 3/16/84 Problem Statement, Allegation #139 w/ attachments (4 pages).
19, 3/16/84 Problem Statement, Allegation #213 w/ attachments (5 pages).
20.
3/22/84 Problem Statement, ATS No. RV84A0043/QS-84-018 w/ attachments (7pages).
21, 3/23/84 Ltr to Albert Hensler from Ross A. Scarano,
Subject:
RV-84-A-0037 w/ attachments (5 pages).
I FOIA-84-743 (9thPartial)
APPENDIX T RECORDS TOTALLY WITHHELD - EXEMPTIONS 6 A 7C 1.
6/13/83 Foley' sinter-officeCommunication(1page).
2.
10/6/83 Memo Re:
Correction of Quality Documents (1 page).
3.
12/14/83 Howard P. Foley Document Deficiency Notice (1 page).
4 Foley's Inter-office Comunication (1 page).
s
RE: F0!A-84-743 F01A-84-744 F0!A-84-776 APPENDIX V RECORDS ALREADY AVAILABLE IN PDR j
1.
9/6/83 SECY-83-366, Diablo Canyon Unit 1 Verification Program Staff Recommendations. Accession No. 8309270639. (14 pages) 2.
12/83 NUREG 0675, Supplement No. 21, "SER".
Accession No.
8401170143.
(275 pagec) 3.
3/84 NUREG-0675, Supplement No. 22, "SER".
Accession No.
8403300300.
(400 pages) 4.
7/84 NUREG-0675, Supplement No. 25, "SER".
Accession No.
8408160080. (122 pages)
S.
7/84 NUREG-0675, Supplement No. 26. "SER".
Accession No.
8408220346. (204 pages) 6.
1/31/84 NRC meeting transcript, "Diablo on Review of Small Bore i
Piping Analysis". Accession No. 8402130076. (162 pages) 7.
2/14/84 ASLAB, "Joint Intervenors' Motion to Augment or, in the Alternative, to Reopen the Record, by Joel R. Reynolds.
Accession No. 8402170053.
(24 pages) 8.
3/20/84 ASLAB (ALAB-763), "Decision". Accession No. 8403210159.
(122 pages) 9.
3/15/84 ASLAB, "Affidavit of James P. Knight". Accession No.
8403190102.
(16 pages) 10.
3/15/84 ASLAB, "Affidavit of Dr. Mark Hartzman". Accession No.
8403190106.
(22 pages)
- 11. 6/11/84 ASLAB, "Joint Intervenors' Reply to PG&E and Nrc Staff Responses..." by Joel R. Reynolds. Accession No. 8406150299.
(19 pages)
- 12. 6/26/84 PG&E letter to NRC, from J. O. Schuyler to Harold R.
Denton, No. DCL-84-239, "Joint Intervenor Allegations".
Accession No. 8407050122.
(172 pages) l
RE: FOIA-84-743 FOIA-84-744 FOIA-84-776 i
APPENDIX U (Continued)'
RECORDS ALREADY AVAILABLE IN PDR
- 13. 6/1/84 PGaE letter to NRC from J. O. Schuyler to Darrell G.
Eisenhut, No. DCL-84-203, "License Condition 2.c (11) -
Final Report". Accession No. 8406110231.
(66 pages)
- 14. 8/10/84 NRC Decision, CLI-84-12. Accession No. 8408140009.
(29 pages)
- 15. 8/10/84 NRC Decision, CLI-84-13. Accession No. 8408140006.
(25 pages)
- 16. 2/7/84 PG&E letter to NRC, from J. O. Schuyler to Eisenhut, No.
DCL-84-046. "Small Bore Piping". Accession No. 8402090241.
(52 pages) j
- 17. 2/15/84 PG8E Letter to NRC, from J. O. Schuyler to John B.
Hartin, No. DCL-84-060, "Snubber Optimization Program".
Accession No. 8402210061. (2 pages) 18, 4/84 PG&E letter to NRC, from Schuyler to Denton, No.
DCL-84-131, "Response to Board Notification 84-071".
Accession No. 8404190003.
(121 pages) 19.
4/18/84 NRC letter to PG8E, from Eisenhut to Schuyler, "Order to Modify Facility Operating License No. DPR-76 (DCNPP, Unit 1)".
Accession No. 8405020134. (5 pages)
- 20. 6/26/84 PG&E letter to NRC, from Schuyler to Eisnhut, No.
1 DCL-84-238, "Additional Information Regarding Piping and Supports". Accession No. 8406290309. (20 pages) i
GOVERNMENT ACCOUNTADil.lTY PROJECT institute for Policy Studies 9901 Que Street. N.W., Washingtco. D.C. 20009 (202)234 9382 September 13, 1984 M
Ofie f Administration I
U.S. Nuclear Regulatory Comission
%Q gy pg Washington DC 20555 To Whom It May Concern:
h $ -/ ').
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. $552, the Government Accountability Project (GAP) request copies of any and all agency records and information, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, files, graphs, engineering analyses, charts, maps, photo-graphs, agreements, handwritten notes, studies, data sheets, notebooks, books, tele-phone messages, computations, voice recordings, any other data compilations, interim and/or final reports, status reports, and any other records relevant to and/or generated in connection with the Safety Evaluacion Report related to the operation' of the Diablo Canyon Nuclear Power Plant, Unit 1 and 2, NUREG-0675, Supplement No. 26, which provided the NRC Staff's further findings on whistleblower charges.
We request that each responsive document be identified by the allegation number (s) to which it may relate.
If any of the materials covered by this request have been destroyed and/or removed, please provide all surrounding documentation, including but not limited to a de-scription of the action (s) taken, relevant date(s), and justification (s) for the actio1(s).
GAP request that fees be waived, because " findings }nformation can be considered as primarily benefitting the general public," 5 U.S.C. 5552(a)(4)(A).
GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through legal representation, advice, national conferences, films, pub-lications and public outreach, the project promateau whistleblowers as agents of government accountability. We are requesting the above information as part of an on-going monitoring project on the adequacy of the NRC's ef forts to protect public safety and health at nuclear power plants.
For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portion of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld.
This index is required under Vaughn v. Rosen(I),
484 F.2d. 820 (D.C. Cir.1973), cert. denied, 415 U.S. 977 (1974).
We look forward to your response to this request within ten days.
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Yours truly, v
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mas Devine Crystal Dixon Legal Director, CAP Legal Intern
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GOVERNMENT ACCOUNTADIUTY PROJECT Institute fo( Pohcy Studies 1901 Ove Street N W.Woshington D C 20009 (202)234 93 %
September 13, 1984 FREEDOM Of INFORMAllOh ACI RE h g,, QUEST Director Of fice of Administration 7
bY U.S. Nuclear Regulatory Commission k #g p.,j Washington DC 20555 To Whom It May Concern:
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. $552, the covernment Accountability Project (CAP) request copies of any and all agency records and in format ion, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, files, graphs, engineering analyses, charts, maps, photo-graphs, agreements, handwritten notes, studies, data sheets, notebooks, books, tele-phone messages, computations, voice recordings. any other data compilations, interim and/or final reports, status reports, and any other records relevant to and/or generated in connection with the Safety Evaluation Report related to the operation of the Diablo Canyon Nuclear Power Plant, Unit 1 and 2, NtREG-0675, Supplement No. 22, which provided the NRC Staff's further findings on whistleblower charges. We request that each responsive document be identified by the allegation number (s) to which it may relate.
If any of the materials covered by this request has been destroyed and/or removed, please provide all surrounding documentation, including but not limited to a de-scription of the action (s) taken, relevant date(s), and justification (s) for the action (s).
GAP request that fees be waived, because " findings information can be considered as primarily benefitting the general public," 5 U.S.C. 5552(a)(4)(A), GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through 1eg,a1 representation, advice, national conf erences, films, pub-lications and public outreach, the project promotes whistleblowers as agents of government accountability. We are requesting the above information as part of an on-going monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or portions that you deny due to a specific F01A exemption, please provide an index itemising and describing the docuneents or portion of documents withheld. The index shou?d provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn_ v. Rosen(I),
~
484 F.2d. 820 (D.C. Cir.1973), cert. denied, 415 U.S. 977 (1974),
We look forward to your response to this request within ten days.
? m Q ? //hl'y l 0 N&
d 'Cr stal Dixon Thomas Devine Legal Intern Legal Director 4
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GOVENMElf ACCOUNTADIUTY PROJECT 1555 Connecncut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232 8550 Freedom of Infomation Act Request FREEDOM OF INFOR_MATION ACf REQUEST fN e f Administration Nuclear Regulatory Comission Washington, D.C.
20555 y, y.-g To Whom It May Concern:
Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. $552, the Government Accountability Project (GAP), requests copies of any and all agency records and infomation, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, legs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer run-offs, any other data compilations e interim and/or finel reports, status reports, and any and all other record's relevant to and/or oenerated in connection with the "Safety Evaluation Report" related to the operati~on of Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Docket Nos. 50-275 and 50-323).
This report was published by the NRC Office of Nuclear Reactor Regulation in July 1984.
This request includes all agency records as defined in 10 C.F.R. $9.3a(b) and the NRC Manual, Appendix 0211, Parts 1. A.2 and A.3 (approved October 8,1980), whether they currently exist in the NRC official,
- working," investigative or other files, or at any other location, including private residences.
If any records as defined in 10 C.F.R. $9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed after this request.
please provide all surrounding records, including but not limited to a list of i
all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
GAP requests that fees be waived, because "finding the information can be con-i sidered as primarily benefitting the general public," 5 U.S.C.j552(a)(4)(a). GAP is a non-profit nonpartisan public interest organization concerned with honest and open governm,ent.
Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the gmtr3
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Director Of fice of Administration Page Two health and safety of their communities. The Citizens Clinic is currently assisting citizens groups, lochi governments and intervenors in connection with investigations of the Diablo Canyon Nuclear Power Plant in California.
We are requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or portions that you deny due to a specific FO!A exemption, please provide an index itemizing and describing the documents or portions of i
documents withheld.
The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to i
the document or portion of the docu:nent withheld. This index is required under Vaughn v. Rosen (1), 484 F.2d 820 (D.C.Cir.1973), cert. denied, 415 U.S. 977 (1974).
Yours truly.
Thcmas Devine Legal Director M J C (x t f Richard E. Condit Legal Intern
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March 23, 1984 PGandE Letter No.:
DCL-84-113 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re:
Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 Welding of ASTM A-325 Type 1 Bolts
Dear Mr. Martin:
PGandE Letter No. DCL-84-067 dated February 17, 1984, provided the NRC Region V Staff with the basis for acceptance of welded ASTM A-325 bolting in pipe support design.
PGandE Letter DCL-84-078, dated February 29, 1984, supplemented the information previously provided and identified additional testing to be performed on A-325 welded bolts by PGandE.
The enclosure to this letter provides the results of the PGandE testing program and describes further action regarding the welding of ASTM A-325 bolts.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, p3 n Schu r
Enclosure cc:
T. W. Bishop D. G. Eisenhut H. E. Schierling Service List gg26 h
PGandE Letter No: DCL-84-113 ENCLOSURE WELDING OF A-325 TYPE 1 BOLTS BACKGROUND PGandE Letter No. DCL-84-067, dated February 17, 1984, provided the basis for acceptance of welded ASTM A-325 bolting in pipe support design. PGandE Letter No. DCL-84-078 dated February 29, 1984, supplemented the information previously provided and detailed a testing and examination program to demonstrate qualification of these welded bolt installations.
In the February 29, 1984 letter, PGandE also identified two discrepancy reports prepared to document the inappropriate specification and application of welded A-325 bolting. These are PGandE Engineering Discrepancy Report No. 84-015-P and Contractor (Pullman Power Proa6 cts) Discrepancy Report No. 5739.
The following summarizes results of the PGandE program associated with closure of these Discrepancy Reports and describes further action regarding the issue of welding 5/8" ASTM A-325 Type I bolts.
RESVLTS The results of PGandE action to close the Discrepancy Reports are described below:
Pipe supports using welded A-325 Type 1 studs were reviewed. This review revealed that ten pipe supports specified the welding of A-325 bolts to A-36 base material. All ten supports are on the CCW system and attached to the containment fan cooler support structure. These hangers are 43-4G, 43-5G, 43-6G, 43-7G, 43-8G, 43-9G, 59N-1G, 59N-2G, 59N-3G, and 59N-4G.
Further review of the corresponding as-builts for these hangers showed that eight of the ten supports actually used A-325 welded studs, and two of the ten supports used A-307 welded studs.
To reinforce the assertions made that the A-325 Type 1 bolts were indeed weldable, PGandE performed additional tests at the jobsite. Four 5/8" A-325 studs were welded to A-36 plate using a full penetration weld, and welding parameters used for the existing installations. The welding procedure utilized low hydrogen E7018 electrodes and an ambient preheat.
These welds were subsequently examined using visual and liquid penetrant methods. The results of these examinations showed no cracking in the weld or heat affected zone of the A-325 stud material.
Further, these four test samples and 80 of the installed bolts were satisfactorily torque tested to a load equivalent to the 20,000 psi allowable stress for A-307 bolts established by the ASIC Manual.
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l The NRC citnessed the above welding exaoinations and torque testing and the
'torqu,e testing of bolting on supports 43-6G, 7G, and 8Go I
A chemical analysis of typical A-325 Type 1 bolts at the jobsite was also performed. The results sliowed a range of carbon from 0.39 to 0.41 percent, with only trace amounts of alloying elements.
The test results support the fact that 5/8" A-325 bolts in question can be satisfactorily welded to A-36 plate using low hydrogen type electrodes and that the as-built condition meets design requirements and applicab'le AISC requirements.
Even though the welded A-325 bolts have been demonstrated to be acceptable, PGandE has elected to revise these pipe sup> orts to weld the base plates to the fan cooler structure in lieu of using t1e subject A-325 bolted connection. This decision was made to eliminate further questions which may arise concerning the application / acceptability of welded A-325 Type 1 bolts.
0642d/0005K _
Exhibit 1 (34 pa go s) x.
I,anuary 2,1984 i
Mr. Mark Padovan Resident USNRC P. O. Box 369 Avila Beach, CA 93424
Dear Mr. Padovan:
This letter is the information we discussed in my Dec. 23 phone conversation with you.
I was a quality control inspector for Pullman Power Products, Diablo Canyon from July 25 to Dec.15 of 1983.
During this time I worked in the rupture restraint and piping support programs performing visual, dimentional, and welding inspec-tiens in unit I and unit 2.
Dates mentioned in this report before Dec. are approximate because all paperwork including personal notes, inspection logs and
{
memos were confiscated by Pullman.
Information copies of the doc-uments that I needed to properly make this report were flatly denied by Pullman.
However, should you find that this report has no legal standing without that data: could the N R C make those papers avail-able to me so that I may assemble a legal report?
The allegations in this report have serious consequences.
The incidents are presented in a chronology to show how Pullman provided for evaluation of deviations presented by myself and others.
Sect 20
- 1. Deviation from the requirements of contract specification 8711.
- 2. Failure to notify purchaser (PG&E) of past and.present devi-a tions,
- 3. Failure to notify the Commission as required by 10 C F R 21.21 b)
Addressed memo to Harold Karner. Pullman's Q A manager, re-garding PG6E's contract specification 8711, Sec.1. Para 7.10.1.
The contract stated that all GTAW shall be performed with a power supply equiped with 1) High frequency for are initiation, 2) Rheostat for stepless control of current.
r I. /a al/i/ -
o 'Mk c-i. t. / f Information in this recoy was defelei in accordance with th Freedom of gormation
- #k E"'"2 b d ',q v 6 -IO / A
/
Research indicated that in the 1977 revision of weld pro-cedures Pullman had failed to include this requirement in their updated Weld Procedure Specifications, WP S s.
Further, P G 6' E approved of the Pullman changes to the weld procedures and. in
' effect ceased to enforce PG&E's own procurement document.
In verbal discussion with Harold Kamer I informed him that none of Pullman's GTAW machines could presently meet the specifications of 8711.
Harolds reply was " if PG&E doesn't en-force the contract Pullman doesn't intend to."
I then informed Har-old that in lieu of the high frequency the welders were scratch starting each time the are had to be initiated thus contaminating the weld with tungsten.
I also told him of the defects I was seeing as a result of no current control devices and no off/on switch on the power supplies Pullman was using.
The defects occur at the end of the weld cycle when the welder tries to ex-tinguish the are by pulling the tungsten electrode directly out of the area over the weld pool.
The weld pool is kept molten as the are elongates but then starts to freeze as the are and mag-nette field collapse, oscillating the still liquid pool, and creating a hole at the center point of the weld pool.
PG &E's contract writers were aware of these types of de-fects typical to GTAW when they wrote 8711 specifying the type of equipment to be used.
Certainly a higher level of quality is obtained when using the proper equipment and if this higher level of quality was thought to be obtained when documents such as the FSAR were written: then a problem has occured.
No reply to my memo has been recorded as of my termination date 12/15/B3.
Sect 22_
- 1. Failure to impliment the quality assurance program as spec-ified in 10 C F R 50, a p p e n dix B, criteria II & X.
A welder was going to' start welding when I asked him to at-tach an argon flow meter near the torch in his GTAW process.
The welder refused to cooperate saying that as long as there wasn't a holdpoint on the process sheet for it the inspector didn't have to check it.
The welder's foreman and my QC supervisor were called in to mediate.
The QC supervisor, Merle Edgerton, said he thought my inspection was a bit excessive.
I reminded Merle that a 20 CFH flow rate was specified by the WPS and that if I was not allowed to check it. when I thought it necessary, then he could riet someone else to do the job.
I was requested to perform inspections elsewhere and left.
2
Sect 2_6
- 1. Failure to issue and maintain adequate document control as required in 10 C P R 5 0, appendix B, criteria VI.
I requested a copy of Pullman's welding procedures at least five times from my superiors Gary Sawer, Jim Cunningham, Russ Nole. Pat Watson, and Harold Karner.
Mr. Karner's response 1
was that too many copies of the weld procedures had already been issued and that the logistics of controling them had become un-mana gable.
Oct.
4-
- 1. Failure to provide adaquate control over inspection and pro-cess monituring as required in 10 C F R 50. appendix B, criteria X.
)
I was requested to inspect a full penetration weld attaching a stanchion to a pipe. Upon arriving I found the craft had welded the cover plate on the free end of the stanchten.
I didn't accept the werk because I was not given an opportunity to evaluate the profile of the back side of the weld.
QC supervisor, Russ Nolle, instructed me to accept the work.
I protested that the cover should be removed by breaking the tack welds and the back side of the weld inspected.
Russ wculd not permit the cover to be removed saying that the visual inspector had limitations that sometimes did not allow the inspector to view the back side of full penetration weld s.
Started to notice that the welding machines were not cal-ibrated on a regular basis and that tong type portable amp meters were not issued aad were rarely seen in the field.
Oct 6
- 1. Over-extention of weld procedure to situation outside scope of original qualification limits. Violation of 10 C F R 50, appendix B, criteria IX.
I wa s a sked to inspect the fit-up of a threaded stud being welded to the containment liner.
After looking at the weld proced-ure being used I determined that welding small diameter studs was not included in the scope of the procedure.
I called Harold Karner and potnted out that there was almost no similarity between the 3
original procedure qualified on pipe and the present application.
Harold assured me that the 7/8 procedure was qualified for the situation and that they had welded thousands of the studs using that procedure.
I replied to Harold that if Pullman had in-
' tended welding thousands of them perhaps a procedure should have been qualified which specifically included the solutions to prob-lems unique to welded studs.
It was decided that since I had such deep reservations about the procedure being used another in-l spector was asked to perform the inspection.
Later, QC supervisor Russ Nolle came out to explain how WPS 7/8 was used to weld studs.
Russ told me that the backing strip could be deleted provided a back grind was used.
I count-ered Russ by pointing out that if back grinding was intended then the procedure would have included direction as to what ths re-quirements of the back grind would be.
Further research on this subject has shown that the stud material most often being used by Pullman is a bolt material, A 307 The stud is made by taking an A 307 bolt and cutting off the head, then the bolt is cut with a chisel point and subsequently called a stud.
The problem is that A 307 is not a P1 material and can not be used in the present Pullman welding procedure 7/8. (See attach-ments 1 & 2 for information copy of part of WPS 7/8.)
Further, bolting material A 307 was never intended as a welded stud because the only chemical limitations on the product are phosphorus and sulfur contents.
Iastly, the material can not be traced because individual heats of steel are not identified in the finished product. (See attachments 3.4, &5)
Oct. 10
- 1. Work performed without instructions, procedures, or drav'-
ing control in violation of 10 C F R 50, appendex B, crt-terias V & VI.
I had noted that in the rupture restraint work in unit two fillet welds originally performed by American Bridge had enchroached on the areas around bolt holes that resulted in many bolts not seating properly.
As a solution the fillet welds were ground back.
However, I asked the RR engineer if measures were being taken to revise the weld si::es in the area of the bolts on the weld sheets.
RR engineer, Dale Warren, replied that to his knowledge the drawings were not being revised.
4
Oct 12
- 1. Failure to update procedures to current criteria as re'q'uired in procurement document 8833-XR, violation of 10 C F R 50, appendix B, criteria VI.
i Upon rejection of out of tolerance washers to criteria set forth in ESD 243 pertaining to hardened steel washers, Dale Warren,
)
the unit two RR engineer found that the information presented in the ESD was out of date.
I relayed the information to Harold Karner, I
the QA manager, who then failed to notify other inspectors that the ESD was out of date and that new criteria was in effect.
As of Dec.15 ESD 243 had still not been revised and the other in-spectors still did not know of the new criteria.
Oct 17
- 1. Failure to provide for inspector evaluation of defects found in items verses the requirments of the procurement documents.
- 2. hilsdirection to inspector by QC supervisor, denial to procure-ment documents, and itimidation for perfor:ning inspection activities as described in 10 C F R 50, appendix B, criteria I.
I had found defects in A-490 bolts sent to the field for in-stallation in Rupture Restraint work being performed in unit two.
The bolts had forging laps visable on the head and I had occasion-ally seen longitudnal quench cracks on the shaft.
I consulted the procedures, ESD 243, and found that the ESD had no rejection crt-teria for the bolts.
I rejected the bolts and then proceeded to search for the pro-ct.rements referenced in the ESD to find the proper status of the items in question. While making copies of an ASThi standard in the office Russ Nolle asked me outside for a discussion.
Russ said that I would no longer be allowed to look at or make copies of:
the AISC Construction Manual, the ANSI or ASTM Standards, or the ASME Codes.
By seeking information in those documents you are beyond your scope as an inspector, "you have your ESDs. "
I replied that ESD 243 did not address inspection criteria for A-490 bolts.
Russ said to me "any conditions found outside of the scope of the ESDs shall be accepted."
I told Russ that I would not be able to abide by that and if the ISDs did not cove-the situation, then, I would seek inspection criteria elsewhere.
Russ got pissed and said that he and Harold Karner have "had it up to here," pointing to his neck.
"You got one foot out the door.
Mr. I.cek ert, one more wrong move and you're gone."
5
Oct 20 l
- 1. Deviatien from the technical requirements inclsded in the procurement documents 8833-XR and AWS DI.0-69.
- 2. Failure of both PG&E and Pullman to regularly review' the status and adequacy of the QA program in violation of 10 C F R SO, appendix B, criteria II.
I had reviewed Pullman's ESD 202, Welding Electrode Con-trol, verses my own copy of AWS DI.1-83, Structural Welding Code.
In the ares of storage of low-hydrogen electrodes I had found a j
discrepency in that Pullman's requirements were below those speci-fled in the code.
I sent a memo to Frank I.yautey, assistant QA manager, tel-ling him what I had found and asking him to check his copy of AWS Dl.0-69, the document referenced in 8833-XR, to see tf we really had a problem.
Pullman's ESD stated that the minimum re-i quired storage temperature for low-hydrogen electrodes was 225* F while I had noticed that AWS required 250' F.
Some time later I was contacted by Frank and informed that I was correct in that the 69 version of the code also required the higher temperature.
Frank went on to assure me that he had per-sonaly checked the logs and that no violations had occured and that he was issuin; a memo immediately to notify all other con-cerned parties.
\\
Oct. 24
- 1. Cver-extension of welding procedures outside the scope of original qualification limits.
Misuse of prequalified pro-cedures per AWS in violation of 10 CFR 5 0. a ppe ndix B,
c r i t e r i a IX.
i I examined the procedure qualification requirements of AWS D1.1 and compared them to Pullman's Rupture Restraint welding pro-gram. It appeared to me that Pullman had taken a WPS qualified under the ASME Sec. IX criteria and transfered the qualification to the AWS criteria. To my knowledge this is permiss ible in that the mechanical requirements of the PQR (tension and bend tests) are transferable to both codes.
However, one of the main points in the application of the WPS to field welding is that joint design is an essential variable in the AWS D1.1 code while in ASME it is not.
I started to look at the process sheets coming out to the field and noticed that 6
Pullman was welding a variety of seven different joint designs and calling it all out as one WPS 7/8.
A clcser examination of Pullman's RR welding prograid re-vealed that they were working with two documents: WPS 7/8 and a Welding Technique Specification called AWS 1.1 ( see attachments 6 thru 11 and 12 thru 14.) The welding procedure 7/8 when applied to AWS welding only qualifies the original joint design used in the PQR because joint design is an essential variable.
The Welding Technique Specification AWS 1.1 has been used as some kind of prequalified procedure not able to stand on its own but in some way attached to WPS 7/8 A close look at AWS 1.1 will show how the nature of this document changes:
- 1. The title of the document says ' Welding Technique Spect-fication" but notice that it also called a WPS on pages 2
& 3 (upper right corner).
- 2. Note that the supporung PQRs are prequalified. Why would a technique specification require any qualification record ?
A technique specification has no legal beanng under any code but a WPS surely would.
- 3. The pennissible base metals listed include A-515 and A-588.
The former is not listed under the steel specifi-cation requirements of AWS D1.1, Table 4.1.1 and the latter requires special welding procedures for impact loading er weathenng applications (see note 6 of Table 4.1.1.)
In order for Pullman to use prequalified joint designs for its use in rupture restraints all mandatery code requirments must j
be met as shown in AWS DI.l. Table El not to mention the least i
of which is a written WPS Pullman can not use prequalified joint designs because "Welding Technique Specification AWS 1.1" is not a WPS ner does WPS 7/8 extend into the realm of prequalified procedures because it does not incorporate all aspects of Dl.1
)
either.
l My first comments on the apparent discrepency were with Russ Nelle.
Russ said not to get excited because someone had already caught it in an audit. (Could Russ be refering to audit a 35 perfonned by Harold Hudson back in March of 83 ?)
7
su i
r O ct. 25
- 1. Attempt to decieve Pullman QC inspector of PG&E'sitola-tion of its own procurement documents.
- 2. Failure to notify the Commission of deviation from procure-ment document 8711, violation of 10 C F R 21.21.
j i
I was still concerned that work was being performed out-side the scope of 8711, PG&E's contract with Pullman for piping and pipe supports.
Recently, I had heard of 200 welds in sched-ule 10 stainless steel pipe that had failed to meet radiographic standards.
I researched the problem by asking the reader of the radiographs, Pullman's Level III NDT Mike Mckray, what types of defects he was seeing.
Mike told me that many of the defects appeared to be grouped either at the start or end of weld passes and that because of the thickness of the pipe defects (porosity mostly) larger than the head of a pin had to be rejected.
Thinking that the lack of dated GTAW equipment might be contributing to the problem I called PG&E's NPO Welding Engineer Dave Stupi.
Dave had asked for several days to research the 8711 contract himself so that this was my second contact with him.
Dave told me that 8711 was a very old document written at least 3
ten years ago and that I had probebly stumbled on an old copy that had never been updated.
Dave refered me to another PG&E engineer and said I was not to include him in any more discus-siens on the matter.
Nov 2 1
Presented Harold Karner, Pullman QA Manager, written noti-fication of my finding with regards to rupture restraint welding with the WPS 7/8 & AWS 1.1 combination.
Nov. 8
- 1. Failure to recognize a significant condition adverse to qual-ity, failure to take corrective action, violation of 10 C F R 50, appendi.x B, criteria XVI.
I performed an inspection directly underneath the unit two pressurizer in which I observed old work that would be absolutely unacceptable under any code.
Welds were on Rupture Restraints B
l
originally built by another contractor, American Bridge, with the manual SAW or, possibly, FCAW process.
I brought my cdocerns to Russ Nolle but he said no, nothing can be done about it.be-cause it was another contractor and already accepted.
Nov. 16
- 1. Failure to take corrective action to preclude repetition of significant condition adverse to quality in violation of 10 C F R 50, appendix B, criteria XVI.
- 2. Failure to provide evaluation in a timely manner and co -
ercion to perform inspections to procedures shown to rea-sonably questionable, violation of 10 C F R 50, appendix B, criteria II.
Two weeks before I had informed Harold Karner the prob-lems I was having justifying the welding being performed on rup-ture restraints.
Now I was being asked to inspect again to pro-cedures I had shown were questionable.
I told my leadman, Jim Cunningham, what I had found and that I had not rec eived a proper response from Mr. Karner.
Un-till I get one I don't feel I should go inspect.
Jim told Russ Nelle and Russ acompanied me to Harold's office.
I explained to Harold my situation.
Harold said I was en-titled to my opinion but that PG&E had already approved the pre-sent procedures.
Further, he said I had a choise: I could go out and inspect or I could look for a new job. I informed Harold that I had dor.e everything in my power to get a quality problem cor-rected and that if he was going to threaten me with my job then I had no real choise but to go and inspect.
Dec. 8 Temporarily assigned to the area 10 fab shop.
The area 10 fab shop also houses the welder qualification test bay so that I had the opportunity to witness some of the welders as they per-formed their tests.
After some questions I had directed at the the welders,I noticed that there were perhaps six or seven welders proceding through the activities of the test with no QC interaction.
9 i
i
Iater on, in the afternoon, after observing more testing with no QC participation I walked into the small office area. and struck up a conversation with the production foreman, Art SaYacou.
I asked Art where the QC inspector was at.
Art replied they.
didn't have one at the moment but that he and Pat Watson had
&n understanding." I thought that was pretty interesting so I asked Art if he was qualified as an inspector.
Art replied no.
Dec. 9
- 1. Failure to provide for assurance that all prerequisites for testing have been met, violation of 10 C F R 50, appendix B, criteria XI.
I learned this morning that the QC normally assigned to the welder qualification tests had quit on Dec. 7 at 09:00.
Af-ter further observance of tests being perfonned with no QC inter-action, I checked the requirements of Pullman's Quality Assurance Manual and reviewed the statements in ASME.Sec III.
Wrote memo to Pat Watson, the area 10 leadman/ welding qualification supervisor, noting that Bill Bailey was gone and that I had observed an apparent lack of QC participation in the testing.
I reminded Pat that the QA Manual's paragraph KFP 15.2 specifically stated that a field inspector shall be assigned to the test shop and that ASME. See III, paragraph NA 3764.1 d would not allow a i
prcduction fereman to determine the quality of production welders.
When Pat car.e on his walk through the fab shop I handed him the memo.
Pat after reading the memo would not accept it and walked off.
Sometime later Pat returned and finally accepted the memo.
At approximately 14:00. Frank Lyautey and Chris Neary ap-peared and wanted to know what was going on. Frank is the as-sistant QA manager and Chris is Pullman's welding engineer from William s pert. PA.
I related the story and told Frank that I had notified the proper person in the chain of command about the ap-parent discrepency.
Frank explained that Bill Bailey had quit and that a new inspectg was scheduled to start in the welder qualifications on the 12 In the absence of either inspector.
Pat Watson was performing duties as field inspector in the test shop.
I admitted to Frank that I had seen Pat Watson in the test bay twice on Thursday, the 8th, but that for the majority of the time I had noted no QC at all.
Frank assured me there i
10
was no problem and then Pat Watson joined us and he assured me the inspections had been performed.
I asked Pat what his inten-sions were regarding the welders I had seen qualifying with no QC around.
Pat said he had no requalification tests in mind be-
.cause there was no quality problem.
Frank then asked me to join Chris Neary and add any comments I had to Chris' revision of Pullman's rupture restraint welding.
My discussion with Chris covered his intensions to:
- 1. Restrict application of WPS 7/8 to the original joint i
design shown in the PQR.
(Note that there is no joint shown in the PQR but only a reference to sheet 2 of 10 ?)
2.Use of prequalified procedures for all other applications.
After examination of Chris' notes I brought up the point that he intended to use the same eight or nine prequalified joint designs they had been using before but that he was still grouping them all under one procedure number, AWS 1.1.
I said this could be con-fusing and that it did not appear to satisfy the requirement of a written procedure for each procedure.
For instance, how can a single bevel corner joint have the same written procedure and num-ber as a double V butt weld that requires back grinding and welder access from both sides ?
1 I reminded Chris that under AWS joint design is considered an essential variable. Chris did not see that this was a problem.
i Dec, 12 I reviewed the events leading up to the confrontatien on the 9" and determined that there still existed some doubt as to wether the qualification tests had been performed properly. Frank 1.yautey and Pat Watson had personally assured me that there was no prob-lem, yet, they had not willingly showed me evidence o.! the in-spection records.
In my own mind several questions remained to be answered:
- 1. Why had I obse ved the qualification tests being per-formed with no QC including Pat Watson present?
2.Why did Art Savacou the production foreman who had ap-peared to be running the show refer to an "understanding" with Pat Watson.
- 3. Did Harold Karner know of the problems I had witnessed in the test shop.
i 11 l
J I refered to the QA Manual and found instructions that said the QA manager was to be informed of problems affecting quality.
I initiated DCN 1/1640-021 that told of what I had'ob-served and that it appeared Pullman was performing work outside qe scope of its own QA Manual.
The Deficient Condition Notice required an engineers signature to be submitted so I asked Mike, the area 10 engineer, to cosign the DCN.
Mike declined te sign the DCN because it showed no hard evidence of a hold point being passed.
Mike did say, how-ever, that if I did provide evidence then he would sign the DCN.
D ec.13
- 1. Failure to provide inspector access to records showing that a function pertaining to quality was adequately per-formed, in violation of 10 C F R 50, a p p e n d i x B, cri-teria I.
After informing RR engineer Dale Warren that I would not accept their previous performance of a stich weld observed on the construction of square beams, I decided that I would inspect the records of the test shop during the time of Bill Bailey's ab-sence.
I went to the test bay and explained to Art Savacou that I had reason to doubt that the welder qualificatien test surviel-lance inspections i.e. materials, process, position, fitup, root-pass, WPS parameter verification, final visual, bend tests had been performed.
Art refused me access to the records saying that only his direct supervision could look at the records.
I informed Art that by doing so he was denying a QC inspector the right to inspect records.
Art's reply was "what are they going to do - put me in j ail ? "
I left the test bay and contacted Pat Watson asking to see his records for Dec. 7,8. 69 concerning welder qualifications.
After some discussion Pat showed me what he had, the records showed a summary of the welders who had qualified, who passed.
who failed.
I told Pat that this was just a summary and that the records did not show wether the required inspections had been performed.
Upon leaving, I reminded Pat that I was still waiting for a written response to the memo.
S y
---m---pe,-----.~w, y.o
i j
l Dec 14 2.
- 1. Failure to notify authorized personnel of changes in Quality Assurance Program in violation of 10 CFR 50, appendix B, criteria VI.
For the events of the morning supposedly causing my termi-nation see Pullman's Termination Notice to Payroll Dept., pages 1 and 2 and my grievance addressed to Mr. Stieger, pages 1-5. (At-tachments 15 through 21 )
In the afternoon after checking a portable rod' oven that had yielded repeated violations of the minimum temperature allowable for low hydrogen electrode storage, I asked the welder to get a-nother rod can because this one appeared defective.
The QA rod room attendent came over after checking the can and asked what the problem was.
I replied that it was below the 250 F min. re-quired by AWS Dl.1.
He said that the ESD only required 225 F.
I replied that ISD 202 had been changed back in October.
The QA rod room at-tendant didn't believe me because he had n't recieved a memo on i
the subject. I showed him my copy of DI.1 and he agreed that was what the code read but that he couldn't change the rod even temperatures until he recieved word from his supervisor.
{
Dec. 15 See page four of grievance (attachment number 21.)
The events I have presented have been shown to be in disregard of procurement documents, codes and standards, and Federal Regulations.
Of course, only the Commission has the nght to interpretation of the Federal Regulations but that does not mean that each person involved in the nuclear industrf is denied their own inference.
I have provided what documentation I could and I ask that the NRC provide me access to the records on site so that I' may provide you with the necessary hanger and rupture restraint numbers for your own investigation.
All events and conversations are true and accurate to the best of my knowledge.
Respectfully, j
/, /
13
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February 29, 1934 PGandi Letter Wo: OCL-04-000 1
Hr. Jonn B.14artin, Regional Administrator U. S. duelear Regulatory Comission, Region V 1450 liaria Lane, Suite 210 Walnut Creek, CA 94596-5360 Re: Docket do. 50-275, OL-OPR-76 uf ablo Canyon Unit 1 SECf G4-til, Iteas 65 and 167
)
Oear 14r.1lartin:
At the January 19, 1904 cxit interview at Diablo Canyon Power Plant, tiie HRC raised questions regarding contractor quality records.
In response to those questions, Puandi is providing the enclosed description of the program for H. F. Foley Company quality records review and turnover to Puandi.
With regard to Pullaan Power Products ("Pullaan") records, Pullman turned all quality records over to PGandi in 1977 and 1901.
A small portion of these records has been returned to Pullman to facilitate nodifications perfomed following the turnover, quality records of all other contractors have been turned over to PGandi.
Kindly acknowledge receipt of this naterial on the enclosed copy of this letter and return it in tue enclosed addressed envelope.
Sincerely, f b
.. m..y s er r-v.
Enclosure cc:
- p. u. Eisenhut H. E. Schierling l
Service List h!f rr h5 O'.
i m b L.j
[4-cGI
1 1
PGandE Letter No. DCL-84-080 ENCLOSURE I
2 PCandE RESPONSE ON FOLEY QUA1,ITY ASSURANCE RECORDS I.
REQUEST POR INFORMATION On January 17 and 19,1984, represintatives of NRC Region V reqtested Pacific Gas and Electric Company (FGandE) to describe the program for H. P. Foley Company (RPF) quality records review and turnover tc PGandE.
II.
PROGRAM DESCRIPTION The program for review and turnover oi' Unit 1 records from HPF to PGandE consists of the following elements:
Record Definition a.
B.
Record Review C.
Verification That Records Cover All Activities and Work D.
Turnover Program E.
Records Storage The details of these elements, including a discussion of past and current practices, follow:
A.
RECORD DEFINITION PGandE contract specifications for HPF work require the contractor to retain all quality-related records for a period of ten years and contain a listing of typical typer and categories of quality records consistent with 10CFR50 Appendix B.
contact PGandE and obtain direction for recorde dispetition.At the end of th A typical specification disclosing records retention is attw:hed (Attachment 1).
PGandE will provide additional written direction to HPF by March 5,1984, further defining quality records and identifying those records which are to be turned over to PGandE.
B.
RECORD REVIEW Foley quality records have been continuously reviewed by HPF and PGandE since 1970.
During the entire period of HPF involvecent at Diablo Canyon, each HPF quality control (QC) discipline supervisor has been responsible for perforcing an independent tecnnical record review of quality records associated with work perforced in that discipline.
This responsibility has continued until the present and is documented in HPF Procedure QCP-17. However, a significant change in record review methodology occured in June 1983.
provided in Section B.2.
The details are 03184 _ _ _ _ _ _ _ _ _ _ _. _ _ _
I B.1
. REVIEW OF MPP 1970 - 1977 RECORDS From 1970 to 1977, HPF's work was limited to electrical installati a
'e activities.
During this period, the quality on of the physicaf work and
'T General Construction Quality Control (GC/QC) and Qua s
organizations.
installations, documentation packuges, and other quality-rela Additionally, HPF conducted its own extensive progra ecents.
s.
inspections of records.
conducted some 600 audits of records activities.Indeed, in the period 1970 In particular, a series of 18 audits of RPF records management were in 1976 These audits specifically centered on document control, quality r orced adequacy, and retrievability.
detailed technical reviews of electrical quality recordsThese random sample a discrepancy reports.
, including or modifications; bovever, some of the clerical and/or admini prompted a further review of records to verify proper record quality ngs documented in a 90-page audit report.The review of all remain
\\
as been were resolved without plant modification. Findings identified durits this review PGandE to verify that HPF had properly identified and imple=ent dFollow action.
As a result, PGandE has a high level of confidence that HPF ha e corrective adequate documentation to support the quality of the Diablo Canyon s
r.
B.2 REVIfV 0F KPF 1977 - 1984 RECORDS In 1977 HPP's scope of work vas enlarged to include the inst ll ti and architectural installation.cechanical equipment, instrumentation, K a a on of majority of RPF activities was concentrated on electrical and instruNo v
vork, including TMI related work.
mentation However, beginning in 1982, HPF's work activity increased significantly due to construction activities associat d with rodifications arising from the Corrective Action Program (d t il d i e
P0andE Phase I Final Report).
ea e n the performed 358 audita of RPF's construction activiti n
documentation.
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The increase in HPF's work force (from 403 in September 1981 to 3 371 peak of construction in August 1983) prompted additional actibus to ass at the that KPF quality records documented during this period were a/ equate e
Accordingly, in the Spring of 1983, PGandE directed RPF to perfor j
e the technical and administrative adequacy of all HPF recordsicompleted dur m a review of
! and af ter September 1981.
order to assure that all quality records completed during and afte ng increase in HPF work were included in the review.
applied both to previously-reviewed and accepted records closed betweenThis ne September 1981 and June 1983 and to new records completed after Ju not part of the sample used to draw conclusion 1 c pre-September 1981 records.
information concerning the adequacy of all HPF quality record work.
y The review was divided into two parts--technical and administrativ installation as described by current design documents. tech e.
The review verified that the records were properly prepared by qualified The administrative individuals.
were properly corrected, all blanks were filled, sheets we numbered, and proper reference was made to procedures and other docum qualified, initials were in accordance with the signature records received proper management approval.
, and B.2.1 RESULTS OF RPF POST-SEPTEMBER 1981 RECORI)S modes 3, 4, and 5 is now complete.The technical review of records r nal be reviewed for modes 2 and 1.
Very few additical records are required to records is approximately 35% complete.The administrative review of all quality a total of 32 deficiencies.
Both of these reviews have identified physical rework or modification:the identification of the followinj or may require l
1.
One electrical raceway support was added due to an overspan co diti n
on.
2.
identification numbers.Five electrical raceway supports required re-sten 3.
Cable traceability could not be readily established for 31 circuits The remainder of the findings were resolved without physical rework or modification.
physical inspection and verification of the adequacy of in so=e cases, review and acceptance by Engineering of the as-built conditi
, in plant installations.
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No significant systematic or generic problems were identified in this review.
Tee one electrical raceway support which required physical work as a result of the review does not indicate any systematic or generic problem vben one considers the large number of installations for which quality records were reviewed.
Nor did the electrical raceway support re-stencilinglyepresent a sLgnificant finding, since the physical work required was not necessary for 4be supports to meet all design requirements.
As for the cable traceability matter, this particular item had not previously been reviewed in detail. Accordingly, prior to power ascension, HPF will verify traceability of all design Class I cable installations.
B.3 REMAINING REVIEW ACTIVITIES OF HPF RECORDS In response to questions from representatives of ERC Region V concerning HPF records review and turnover, PGandE proposes the following progra for the re=aining record review activity. The program is based upon the results of the post-September 1981 records review as discussed in Section B.2.1.
This four-part program will provide added assurance that the quality records documenting HPF's work are of acceptable quality. The program includes reviews by HPF and PGandE and spans the entire time period associated wit' HPF work. Further, this program provides for both technical and administrative reviews of the records where appropriate.
However, some categories of work have been e.teluded from further review as noted in Attachment 2.
1.
HPF post-September 1981 records review.
HPF will revise the procedures for the post-Septe=ber 1981 records review program to enhance its effectiveness, and will co:plete the program prior to co==ercial operation.
2.
HPF pre-September 1981 records review. HPF will perform a detailed document review to assure that records were properly prepared. This will be done prior to co:mercial operation.
3.
HPF review of cable traceability.
To provide further assurance of appropriate docu=entation of Class I cable installation. HPF will verify their traceability prior ;o power ascension.
4.
PGandE records review.
PGandE will perform a review of docu ent packaEes turned over by HPF t a assure they have been properly prepared. This review will include inspection, on a random basis, of construction ite:s which are complete and accepted by HPF to verify that HPF quality records adequately document installation according to desi n documents.
E The details of this four-part progra= follow.
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j B.3.1 HPF POST-SEPTEMBER 1981 RECORDS REVIEV.
HPF will complete its post-September 1981 records review.
been structured to the criteria and scope as described in AttTh'is review has upon the review completed to date, the following changes are.achment 2.
Based record review procedures:
being made to (1)
Clarification of the definition of conditions which require issuance of an NCR.
(2)
Clarification of the definition of approval levels and documentation requirements for quality record changes and/or corrections.
(3)
)
Additional training of HPF document analysts in HPF's quality administrative procedures.
The following actions, which will be reviewed and approved by PCa dE being taken:
n, are (1)
Control of Deviations and Nonconformances, to f n
which require the issuance of a Nonconformance Report ons programmatic proble=s not directly associated with the quality of
, including installation and their related corrective actions.
This item is scheduled to be completed by March 15, 1984.
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(2)
EPF instructions which outline the document review process will be l
changes or corrections to quality records. revised to specify th) completed by March 15, 1984.
This is scheduled to be i
(3)
HPF bas incorporated into its training prograc for docu:ent analysts specific directions which assure a uniform method of conducting document reviews.
Training caterials, such as specifications and procedures as well as any discussion on applicable quality ad.inistrative instructions are documented and placed in a training file for each individual.
prior to co ercial operation.The HPF review of records completed after S B.3.2 HPF PRE-SEPTEF3ER 1981 RECORDS REVIEW HPF is perfonsing a review of records completed prior to September 1981 criteria and scope of the review is provided in Attach:ent 2.
The This HPF review has been initiated, and will be co:pleted i
turnover, prior to co= ercial operation.
including record review, including any findings and their significance, will be provi to power ascension.
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l B.3.3 HPF REVIEW OF CABLE TRACEABILITY I
e To provide assurance of appropriate documentation of Class I fable installation, HPF will verify traceability prior to power ascension. This
,,- verification effort will include a review of each pull package' by circuit.
. B.3.4 PGandE RECORDS REVIEW In addition to tho HPF review, PGandE will perform its own administrative review of documentation packages turned over to PGandE by HPF. This review will parallel the HPF record turnover and will include:
(1) Verification that all documentation packages listed on HPF's index are included.
(2) Verification that all documentation packages have been certified by HPF as being complete and correct.
(3) An audit of the documentation packages. Eachpackageinthehpli vill be completely reviewed to ensure that the package contents are complete, correct, legible, and included according to the package inder.
(4) Cross-references will be developed of Foley NCRs to Foley work packages using PGandE's computer-based Records Managesent System (RXS). This work will be completed during entry of all contractor documents into the RXS.
Verification of all reviews will be documented on Docu:ent Review Reports (DREs). During the review process, document packages and/or individual docu:ents identified as missing, incomplete, incorrect, and/or illegible will be referred to HPF for corrective action.
PGandE will perfor= follow-up reviews on the corrections of the deficiencies noted and, if generic problems are apparent, they will be invectigated and resolved.
Additionally, PGandE CC/QC will continue to inspect, on a random basis, construction items which are complete and accepted by the contractor to confir: the following:
(1) Installation meets latest design documents.
(2) Inspection records are complete regarding inspection activities.
(3) Procedure and specification require:ents are met.
-(4) Required backup docu=entation is supplied (e.g., weld records, me6ger test records, pull tension calculations).
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C.
VERIFICATION THAT RECORDS COVER ALL ACTIVITIES AND VORK
'e To verify that all required quality records are in place and eyailable for transfer to PGandE, HPF will perform crosschecks between work dnitiation
- documents and existing quality records.
This program will be.tontrolled by
! approved procedures and completed for each work package and work activity prior to record turnover to PGandE.
D.
TURNOVER PROGRAM Previous direction to RFP regarding quality records turnover has been provided by PGandE correspondence. The following procedures and instructions provide additional direction for records turnover:
(1) PGandE Quality Assurance Policy Statenent - Quality Assurance Manual,Section XVII, Quality Assurance Records.
(2) PGandE Procedure for Receipt, Review, Indexing, and Storage of Records -
Quality Assurance Department Records Management Handbook, Part II.
In addition, the following procedures and instructions have been recently prepared to provide further direction for records turnover.
1 (1) General Construction Instruction QCFI-3, Document Review of Contractor Generated Records.
(2) General Construction Instruction QCFI-4, Contractor'e Record Turnover.
(3) HPF Procedure QCP-34, Safekeeping, Processing,.nd Turnover of Quality Assurance Records (this procedure has been approved by PGandE).
(4) HPF Quality Assurance Instructions (QAIs) implementing QCP-34. PGandE will review and approve these QAIs to verify proper imple:entation of QCP-34.
In addition, a PGandE turnover task force has been established to review federal, industry, and PGandE documentation require =ents regarding contractor records. This task force is currently creating a generic turnover interface procedure vbich outlines the QA Program records turnover require ents.
All existing turnover procedures and instructions will be reviewed and revised to comply with the turnover interface requirements outlined in the generic turnover interface procedure.
E.
RECORDS STORAGE Currently most HPF quality records are stored in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire-rated file cabinets. The HPF records storage building is being upgraded to include auto:atic balon fire suppression and alarms.
The facility upgrade vill be completed by March 31, 19B4.
In the interim, a continuous security and fire watch will be posted in addition to the existing strict access control.
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After the facility has been upgraded, all completed HPF quality records will continue to be stored in 1 hour-fire rated file cabinets within the facility.
As HPF quality records are turned over to PGandE, the records will be removed
{
from the HPF vault and stored in the GC/QC records storage vau1% which meets i 1 the ANSI N45.2 9 single storage facility criteria.
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PGandE Letter No. DCL-84-083 1
ATTACHMENT 1 in PGandE specifications on the use and maintenance of contract
.C 4.1211 Records:
Contractor aball use, collect, and maintain records and data essential to document the quality of material supplied and work performed under this Specification.
Records are considered one of the principal forms of objective evidence of quality,and i
procedures aball assure that records are complete and reliable.
All records aball be collected and filed at one location at manufacturing abops or at the work site. Records collected ' ball a
include, as a minimum, the following:
drawings, specifications, purchase orders, work orders, inspection reports, test reports, work performance records, work procedures, qualification records for procedures, equipment and personnuel, nonconfor=ance reports, corrective action records, and audit records.
Inspection and test reports aball indicate the nature of observations or tests, and acceptable limits of observations or tests, the results, the type of j
nonconfor:ances observed, and the identity of the observing personnel.
Work performance records aball indicate acceptability of the work and/or caterial or necessary corrective action in cases of nonconfor:ances.
All records aball be preserved by Contractor for use by Cotpany for ten years.
If Company has not requested custody of the records and documents before the end of the ten-year period, Contractor aball request disposition instructions from Company.
Until such tice as they may be transferred to Cocpa.y, the records and documents shall be available for inspection and review by Company and reEulatory agencies.
Upon request, duplicate copies of records and docu:ents for specific items aball be provided promptly by Contractor to Constructor.
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PCandE Letter No. DCL-84-080 ATTACHKENT 2 CRITERIA AND SCOPE OF HPF REVIEW OF RECORDS '.'
.2 I.
CRITERIA A.
All appropriate spaces on the records aball be filled in, paEes aball be in numerical order, and the records package shall be complete.
B.
All data on the records aball be clear and legible.
C.
Signatures, initials and dates shall be authorized, approved, and affixed where required.
D.
Records aball be accurate and properly identified.
Appropriate inspection report references shall be affired.
E.
Records aball be indexed and packaged for turnover to PGandE.
Any problems identified will be promptly corrected in accordance with the modified document review process procedures and, if required, will be docu=ented in accordance with the modified nonconformance procedure.
II.
SCOPE V.ith the exception of certain categories of records in specific tice periods all records will be reviewed. These exceptions include records of installations for which other docu=ents confirm installation and/or perforcance to the extent necessary to validate proper plant operation and maint e na nc e.
from the review.The following is a list of record categories that are excluded A.
Vire Terminations.
Perfor:ance is proven by instrument loop tests, electrical dry run tests, and startup functional tests.
These tests are perfor=ed and documented by PGandE.
Ter=inations are as-built and recorded on PGandE Engineering record drawings.
B.
Vire Installation.
Performance is proven by instrument loop tests, electrical dry run tests, cegger tests, and startup functional tests.
These tests are performed and documented by PGandE.
The as-built configuration of circuits is recorded on PGandE record drawings.
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C.
Raceway Installation.
All raceways were walked down in 1982 and 1983 by Project personnel to verify spacing and location of supp9rts.
The resulting recorded data were reviewed and accepted or modifications were
's issued.
In 1983, Project personnel walked down all Design Class I raceways to verify separation of redundant circuits.
Tbiyefore.
installations completed prior to 1982 are documented and.known to be
~!
correct and no further review of these documents is planned. Record s etcpleted in 1982 and later will be reviewed.
D.
Raceway Support Installation. All raceway supports were walked down and as-built by Project personnel in 1982 and 1983 The resulting data were reviewed and accepted by Engineering or modifications were issued.
Therefore, all installations completed prior to 1982 are docu=ented and known to be correct and no further review of these documents is planned.
Recorda completed in 1982 and later will be reviewed. Velding and anchor bolt installation quality was not verified as a part of these walkdowns and etsineering evaluations. However, the quality of anchor bolt installations has been verified by other reviews and our findings are documented in letters to the NRC dated January 27, February 7, and Februntr 16, 1984. Therefore, all welding records associated with these installations vill be reviewed.
E.
HVAC Duct Installation.
The HVAC system has been tested by Project persottel and consultants to verify air flows at all locations conply with design criteria.
The results are documented. Also, startup tests have been performed, documented, and results accepted.
The duct confiEuration and location are as-built and shown on PCandE dr F.
HVAC Support Installation. All HVAC supports were walked down and as-built by Project personnel in 1982 and 1983.
The resulting data were reviewed and accepted by Engineering or modifications were issued.
Therefore, all installations accomplished prior to 1982 are docu=ented and known to be correct and no further review of these docu:ents is Planned.
Records coupleted in 1982 and later will be reviewed. Veld ing and anchor bolt installation quality was not verified as a part of these walkdowns and engineering evaluations.
However, the quality of anchor bolt installations bas been verified by other reviews and our findings are documented in letters to the NRC dated January 27 February 7, and February 16, 1984. Therefore, all welding records associated with these installations vill be reviewed.
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